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The EU's Cyber Resilience Act: 10 on the 10
Today the EU's Cyber Resilience Act (Regulation (EU) 2024/2847) ('CRA') enters into force. The CRA recognises that the continuously evolving world of smart products is frequently challenged by vulnerabilities which can potentially lead to cyber-security incidents. Whilst most of the Act's obligations will not be applicable until three years from now, 10 December is the day when the EU takes a big step towards it's ten-year Cybersecurity Strategy. To mark the occasion, we have outlined ten key points that entities in scope must be aware of in preparation for compliance with the CRA.
Read moreNew Data (Use and Access) Bill
What does the new Data (Use and Access) Bill (the Data Bill) mean for businesses?
Read moreChanges to the One Stop Shop
In July 2023 the European Commission issued a Proposal for a Regulation of the European Parliament and of the Council laying down additional procedural rules relating to the enforcement of Regulation (EU) 2016/679 (the 'GDPR' Regulations).
Read moreICO publishes guidance on compliance of game design with the Children’s Code
What steps can game designers take to ensure their games comply with the Children’s Code?
Read moreRPC Law x Web3: Gambling regulations – Don't Play Games of Chance with the Law
This is part of a series of RPC x Web3 articles designed to help Web3 participants and enthusiasts understand their rights in this rapidly evolving space.
Read moreSnapshots Spring 2025
A roundup of key legal developments for the modern commercial lawyer.
Read moreSnapshots Winter 2024
A roundup of key legal developments for the modern commercial lawyer.
Read moreSnapshots Autumn 2024
A roundup of key legal developments for the modern commercial lawyer.
Read moreSnapshots Summer 2024
A roundup of key legal developments for the modern commercial lawyer.
Read moreSnapshots Spring 2024
A roundup of key legal developments for the modern commercial lawyer.
Read moreSnapshots Winter 2023
A roundup of key legal developments for the modern commercial lawyer.
Read moreSnapshots Autumn 2023
A roundup of key legal developments for the modern commercial lawyer.
Read moreSnapshots Summer 2023
A roundup of key legal developments for the modern commercial lawyer.
Read moreSnapshots Spring 2023
A roundup of key legal developments for the modern commercial lawyer.
Read moreSnapshots Winter 2022
A roundup of key legal developments for the modern commercial lawyer.
Read moreAll is not (necessarily) lost: Crypto crime recovery
With over 2 million people in the UK now holding and using cryptocurrency, and the Chancellor announcing that a government backed non-fungible token ("NFT") is to be issued by the Royal Mint this summer, the market for crypto-assets is expected to continue to grow in the coming months and years; so much so that legislation is planned to implement a new regulatory regime for the crypto market.
Read moreThe High Court continues interim anti-harassment injunction
At a return date hearing on 12 July 2024, Aidan Eardley KC (sitting as a Deputy High Court Judge) continued until trial or further order an anti-harassment injunction granted to prevent the Defendant from, amongst other things, approaching or contacting the Claimant.
Read moreThe Supreme Court clarifies the law on the recovery of damages for non-pecuniary damage arising out of a maliciously false statement
The Claimant was an employee of the second defendant, LCA, a recruitment agency owned and operated by the first defendant. After leaving LCA, the Claimant was employed by another recruitment agency and began targeting LCA's clients. LCA's owner told two third parties, one of whom was the Claimant’s new line manager and the other a client of LCA, that by doing this the Claimant was in breach of her contract of employment with LCA. In fact, there was no term of that contract (as the owner of LCA knew) which prohibited the claimant from soliciting business from LCA’s clients.
Read moreThe Model Anti-SLAPP Law: an overview
Following the Government's response to the SLAPP consultation in the summer, the UK Anti-SLAPP coalition (a working group that includes English PEN, the Foreign Policy Centre and Index on Censorship, "the Coalition") has this week published a model Anti-SLAPP law, which has been endorsed by a collection of free speech and anti-corruption organisations, journalists, editors and lawyers.
Read moreFTT prevents HMRC from having two bites of the cherry!
In Lady Henrietta Pearson v HMRC [2014] UKFTT 890 (TC), the First-tier Tribunal (Tax Chamber) ('FTT') concluded that HMRC had "ignored" its previous decision by seeking to reduce the amount of a VAT refund which it had ordered HMRC make to Lady Henrietta Pearson ('the taxpayer').
Read moreWhistle-blowing on illegal cartels drops 70% in 5 years
Competition and Markets Authority (CMA) recently increased award to £250,000 Calls to the CMA hotline have plummeted from 1,442 in 2017 to 427 in 2022
Read moreRegulatory Radar: quick takes May 2025
Welcome to the latest edition of our bi-monthly Regulatory Radar: quick takes update, which collates the latest developments from across the UK’s regulators.
Read moreRICS disciplinary process: an overview for surveyors
Download our complete guide to the procedure involved in a disciplinary investigation against a chartered surveyor.
Read moreNew Cryptoasset reporting obligations for businesses
The UK is adopting the OECD’s Cryptoasset Reporting Framework (CARF) and expanding it to include domestic data collection and reporting requirements. Starting from 1 January 2026, businesses operating in the cryptoasset sector will face new obligations to collect and report data to HMRC.
Read moreNew reporting obligations for Cryptoasset users
The UK is adopting the OECD’s Cryptoasset Reporting Framework (CARF) and expanding it to include domestic data collection and reporting requirements. From 1 January 2026, users of cryptoasset service providers will be required to provide identifying information to those providers, which may then be reported to HMRC.
Read moreJudicial developments in recent treaty cases
A spate of recent cases concerning the application of double tax treaties has seen the courts and tribunals striving for common¬sense, policy-driven outcomes.
Read moreJudicial review: does the Court of Appeal’s decision in Murphy offer taxpayers a glimmer of hope?
Judicial review provides a constitutionally important judicial check on the exercise of statutory powers by public bodies such as HMRC. However, the wide margin of appreciation afforded to public bodies by the courts, coupled with recent reforms to the judicial review process, make it a remedy of last resort that can be difficult for taxpayers to pursue successfully. In overturning the High Court’s refusal of the taxpayers’ judicial review claim, the Court of Appeal in Murphy v HMRC confirmed that HMRC had breached their legitimate expectation as to the application of an extra-statutory concession. While Murphy is unlikely to be the harbinger of a wholesale rebalancing of the judicial review scales in the taxpayer’s favour, it is a welcome step in the right direction.
Read moreTaxing Matters: When tax advice goes wrong: professional negligence in tax disputes
In this episode, our host and Senior Associate at RPC, Alexis Armitage, is joined by colleagues Helen Kerr and Tom Wild from RPC's Professional Liability team to explore how professional negligence claims can arise during the lifecycle of a tax dispute.
Read moreUpper Tribunal dismisses IR 35 challenge
In George Mantides Ltd v HMRC [2025] UKUT 00124 (TCC), the Upper Tribunal dismissed the company's appeal against an income tax determination and national insurance decision. Whilst the UT set aside the earlier decision of the First-tier Tribunal on the basis that there were errors in the assessment of the hypothetical contract, ultimately it came to the same conclusion that the hypothetical contract was one of employment for the purposes of IR35.
Read moreImproving HMRC’s Approach to Dispute Resolution
This article considers the recently launched consultation aimed at modernising HMRC’s approach to resolving tax disputes.
Read moreNo Retreat on UK Digital Services Tax – For Now
This blog considers recent speculation concerning the future of the UK's Digital Services Tax in the context of trade negotiations between the UK and the USA.
Read moreCourt of Appeal confirms pre-construction costs qualify for capital allowances
In Orsted West of Duddon Sands (UK) Ltd and others v HMRC [2025] EWCA Civ 279, the Court of Appeal held that expenditure incurred in designing windfarms and on studies informing the installation could qualify for capital allowances.
Read moreTax Bites - June 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreBlowing the whistle!
Adam Craggs and Tom Holden consider the US and Canadian 'whistleblower' models in light of the government's plans for a new reward scheme inspired by these, as well as the existing HMRC rewards scheme this initiative will complement.
Read moreContentious Tax Quarterly Review – Spring 2025
This Contentious Tax Review provides an update on a number of recent important decisions in the tax disputes arena.
Read moreFormer England captain's IR35 battle with HMRC ends in a score draw
In Bryan Robson Ltd v HMRC [2025] TC09408, the First-tier Tribunal considered the IR35 legislation in relation to ex-England footballer Bryan Robson. It found payments made for his ambassadorial role at Manchester United fell within the scope of the IR35 legislation, while payments made to him in respect of his image rights did not.
Read moreTaxing Matters: Mental Health Awareness Week: breaking down mental barriers in the mind with Jo Maughan
In this special Mental Health Awareness Week episode of Taxing Matters, host Alexis Armitage welcomes Jo Maughan, career coach and former tax director, to discuss how professionals can manage their critical inner voice and break down mental barriers in their mind.
Read moreChallenging HMRC's Debt Management Actions - Lessons Learned from Local Fuel Ltd
Michelle Sloane and Daniel Williams consider when a private law action, rather than judicial review, is appropriate to challenge a decision taken by HMRC's debt management team.
Read moreTax Bites - May 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreTribunal allows capital allowances claim for expenditure on construction of a quay wall at the Port of Liverpool
In The Mersey Docks and Harbour Company Ltd v HMRC [2024] UKFTT 1163 (TC), the First-tier Tribunal allowed the company's claim for capital allowances in respect of expenditure incurred on the construction of a quay wall at a new deep-water container terminal at the Port of Liverpool.
Read moreTaxing Matters: Tax risk for professionals and professional businesses with Thomas Slipanczewski, Associate Director at Deloitte
In this episode of Taxing Matters, Senior Associate and Taxing Matters host, Alexis Armitage is joined by Thomas Slipanczewski, who is an Associate Director at Deloitte in their tax controversy team, to discuss task risk for regulated professionals and professional businesses.
Read moreCriminal Offences and Prosecutions for Tax Fraud
Adam Craggs and Daniel Williams consider HMRC's approach to investigation and prosecution of various tax fraud offences, and deferred prosecution agreements and unexplained wealth orders.
Read moreCourt of Appeal confirms that compensatory payments made to settle regulatory investigations are not penalties
In ScottishPower (SCPL) Ltd and others v HMRC [2025] EWCA Civ 3, the Court of Appeal held that compensatory payments made to consumers in settlement of regulatory investigations were not penalties and therefore were deductible for corporation tax purposes.
Read moreBusiness Briefing: Navigating The New US-UK Trade Tariffs
The Trump administration has introduced sweeping tariffs on goods imported into the United States. This move is expected to cause significant disruption to global trade, with notable consequences for UK businesses. As the ripple effects unfold, understanding the scope of the tariffs and how to respond strategically will be crucial for UK businesses looking to protect their margins, adapt their operations, and plan confidently for the future.
Read moreUT allows company's appeal as payment to EBT was not earnings of its employee
In M R Currell Ltd v HMRC [2024] UKUT 00404, the Upper Tribunal set aside the First-tier Tribunal's decision and held that a payment from a company to an employee benefit trust was not taxable earnings as the facts were distinguishable from those in RFC 2012 plc (formerly The Rangers Football Club plc) v Advocate General for Scotland [2017] UKSC 45.
Read moreTax Bites: April 2025
Welcome to the latest edition of RPC's Tax Bites – providing monthly bite-sized updates from the tax world.
Read moreJudicial review in tax disputes – an overview
Judicial review remains an important tool for taxpayers to challenge HMRC's decisions, and it is important for taxpayers and practitioners to have a clear understanding of the judicial review process.
Read moreTaxing Matters: Navigating the human side of tax disputes with Mark Bevington of ADE Tax
In our latest episode of RPC's Taxing Matters, podcast host and Senior Associate, Alexis Armitage, is joined by Mark Bevington managing principal and founder of ADE Tax.
Read moreCourt allows taxpayer's appeal and agrees the "exceptional circumstances" exemption was satisfied
In A Taxpayer v HMRC [2025] EWCA Civ 106, the Court of Appeal allowed the taxpayer's appeal, agreeing with the First-tier Tribunal's decision that the "exceptional circumstances" exemption in paragraph 22(4), Schedule 45, Finance Act 2013, was satisfied.
Read moreHigh Court permits recission in EBT case enabling taxpayers to avoid IHT liability
In JTC Employer Solutions Trustee Ltd and others v Garnett and another, the High Court allowed the claimants' claim and permitted rescission in relation to various Employee Benefit Trust appointments to sub-trusts, with the result that there was no IHT liability as the mistake in creating the sub-trusts was sufficiently serious to render it unconscionable to leave the mistaken disposition uncorrected.
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